Legal

Privacy Policy

Privacy Policy

ONLINE PRIVACY POLICY HIGHLIGHTSThis page highlights some of the key elements of our Online Privacy Policy. Both this page and our Online Privacy Policy apply to www.northpass.com, the official website of SchoolKeep, Inc., which operates under the name Northpass (the "Site") and any authorized online apps or features that may contain a link to this policy. For more information, please read our complete Online Privacy Policy.

Information CollectedThere are two types of information that we obtain from you online, and then store and use:

We do not collect any personal information from you when you visit our sites unless you expressly and voluntarily participate in an activity that asks for it and you voluntarily provide it. To put it another way, FOR US TO HAVE ACCESS TO YOUR PERSONAL INFORMATION, YOU HAVE TO HAVE MADE A CHOICE TO KNOWINGLY GIVE IT TO US.

Uses of InformationWe use voluntarily provided personal information to communicate directly with you including via email, text and phone. We do not sell or rent your personal information to third party data vendors or marketing companies. As you might expect, we also disclose your information when required by law.

We use non-personal information to administer our site, make it better, and to make business decisions about what programs our customers might like.

You do not have to provide personal information to enjoy most of the features of our site. You also can opt out of certain activities like newsletters and announcements by sending us an opt-out email or by following the unsubscribe instructions in each electronic newsletter and email.

Privacy Shield ComplianceWe comply with US-EU Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of certain personal information from European Economic Area member countries and Switzerland. We will collect, use and retain such information in accordance with Privacy Shield Principles.

Thank you for visiting Northpass' online resources and viewing this privacy policy. We use this policy to tell you about the types of information we collect from you when you visit our Site or use authorized features, functionality or apps powered by Northpass (collectively, the “Services”). More specifically, this policy tells you:

• the types of information we collect when you visit our Site or use the Services and how we collect it;• the ways in which we use, share and protect that information;• the choices you have in controlling the collection of your information; and• your ability to access and update your information.

By using our Site and/or the Services, you are signifying to us that you agree with this policy. Although the Site or Services may contain links to other websites controlled by third parties, you should be aware that we are not responsible for the privacy practices of those, or any other, sites. If you have questions about how those websites collect and use data, you should carefully read those sites’ privacy policies.

This privacy policy was amended on November 20, 2017 and is effective as of that date.

Some Important Vocabulary

This privacy policy is a legal document, so clarity is important. We’ll use this section to let you know about some words that have special meanings whenever you see them in this policy. Let’s start with the word “policy” itself: when we reference “this policy”, “this privacy policy” and “our policy”, we mean the Northpass Online Privacy Policy you are reading now. Wherever we say “Northpass” or “we”, “us” or “our”, we mean SchoolKeep, Inc. and its affiliates. We use the words “you” and “your” to mean you, the reader, and other visitors to our site who are, in all cases, over the age of 18. This age requirement is discussed in more detail later in this policy here.

Whenever we reference “this Site”, “our Site” or “the Site”, we mean the Northpass website found at www.northpass.com. When we talk about the “Services” or “authorized features and apps”, we’re referring both to elements of our social media presence viewable from Facebook, Twitter, YouTube, Google+, LinkedIn or any of the many other available external third party social media platforms, as well as mobile or other apps we’ve created and distributed to let our customers and followers view our site or otherwise interact with our content. Last, but definitely not least, when we refer to “personal information”, we mean information that can be used to identify you or that can be easily linked to you. Thus, a fairly comprehensive list of “personal information” would include such things as your name, address, telephone number, fax number, email address, social security number and date of birth. In contrast, a domain name or an internet protocol address would not be considered personal information.

Nothing Personal: Automatically Collected Information

When you visit our Site, basic information is passively collected through your browser via use of tracking technologies, such as “cookies” which utilize various files sent from our servers to your computer hard drive. Although you may turn off the collection of cookies through your browser options, it may hamper your user experience or limit your ability to use our Site. Additional information about cookies and tracking technologies is available here. The information we collect through cookies and other means (such as web beacons, pixel tags and embedded links) is not personal information and does not individually identify you. It includes things like:

• the domain name and IP address from which you accessed our Site• the type of browser and operating system you use• the date and time and length of your visit• the specific page visited, graphics viewed and any documents downloaded• the specific links to other sites you accessed from our Site• the specific links from other sites you used to access our Site

Mobile devices are the one possible exception to the rule that our passive, automatic collection activities exclude personal information. We say that because if you access our site from a phone or other mobile device, the mobile services provider may transmit to us uniquely identifiable mobile device information which allows us to then collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone service providers also operate systems that pinpoint the physical location of devices and we may receive this information as well.

Regardless, we use both automatically collected non-personal information and mobile device information only to compile generic reports about popular pages on our Site, and to see how our customers and followers are accessing our Site or using the Service. We then use that data to administer the Site, fulfill your requests, send materials to you, inform you of offers, make your activities more convenient and efficient, to enhance the functionality of our Site and the Services, such as by remembering certain of your information thereby saving you time and for other purposes permitted by law.

Now its Personal: Voluntarily Submitted Information

If you participate in certain activities on our Site, you may need to provide us with information about yourself such as your name, email address, company name, or phone number. For example, if you choose to send us an email or fill out an online form, complete a survey, register for a class or create or update an account, you are voluntarily providing personal information to us. In doing so, you are giving us your consent to collect, use and disclose that information for the purpose it is requested and for other reasonable internal business purposes including but not limited to providing the Site and Services to you, developing and improving the Services, fulfilling your requests, and sending you materials as further detailed below. We do not sell, rent or trade voluntarily submitted personal information with third parties.

If you don’t want us to collect this type of personal information, don’t provide it! This means you shouldn’t participate in the activities on our Site that request or require it. Participation is strictly your choice. Not participating may limit your ability to take full advantage of the Site, but it will not affect your ability to access certain information available on the Site to the general public.

Here are some of the ways you voluntarily give us your personal information and how we use it:

• Direct Communications - When you send us an email, your email address and any other personal information that may be in the content of your message or attached to it, are retained by us and used to respond back directly to you. If you prefer we not collect, use or store this information, please do not email us or enter this information into the Site. Instead, you may want to communicate with us by phone or by regular mail.

• Registering through the Services; Emails and Newsletters - When you register through the Services, you submit personal information to us which we then retain. We use that information to send you electronic newsletters and emails concerning promotions, new products, and services or other marketing materials.

Note that some authorized features and apps may allow users to post or upload messages, comments, screen names, files and other materials. If you choose to make personally identifiable information public through these means, we will consider that information to be in the public domain and will not limit its disclosure in the manner described by this policy. Although Northpass may ask for your credit card information to process orders, Northpass does not process or retain this information.

Sharing Information Collected with Third Parties, Consultants and Affiliates

We may share personal information with our business associates, consultants, service providers, advisors and affiliates in order for them to provide services to us, to you and to the Site. The information we collect may also be shared with our customers who use the Services, and each customer’s own privacy policy, not this policy, will govern their use of this data. We may also share personal information for the following purposes:

Third Party Providers. We may share your information, including personal information, with our service providers and other third parties that help us operate and/or provide products or services for the Services and our business

Legally Compelled Disclosures. We may disclose your information, including personal information, to government authorities, and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required or permitted by law, including but not limited to responding to court orders, subpoenas or to meet national security or law enforcement requirements. We also may disclose such information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Services, or anyone else that could be harmed by such activities.

Additionally, our Services may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, to help us analyze how users use the Services. You may be able to opt-out of Google’s collection. Please visit Google’s Google Analytics opt-out browser add-on for more information.

Communication Tools

The Services may contain tools that enable you to share personal information, including sensitive information, with others via external third party social media platforms and in other ways. You should exercise caution when using such tools and sharing sensitive information. The Services will not share this information in this manner without your specific direction to do so.

Choices you can make: Opt Out and Account Changes

If we are using personal information you provided to us in order to enable us to send you materials, such as newsletters or product alerts via email, and you decide you don’t want to receive such materials, you may opt out by following the opt-out instructions in the email, newsletter or other communication. In addition, you can always opt out by contacting us at the email address listed below. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. Users also need to understand it may take a period of time to remove your name from our lists after your request and due to such latency you may still receive materials for a period of time after you opt out. In addition to opting out, you have the ability when your personal information is inaccurate, to have it corrected, amended or deleted. You may change certain information through your login credentials or you can contact us at privacy@northpass.com.

Privacy Shield Compliance

Consistent with Northpass’ goal to protect personal privacy, Northpass is fully committed to complying with the US-EU Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EEA member nations and Switzerland to the United States. Northpass has certified to the Department of Commerce that it adheres to both the US-EU and Swiss-US Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability as set forth below (the “Principles”). The United States Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield and we are subject to the FTC’s investigatory and enforcement powers. If there is any conflict between the terms of this privacy policy and the Principles, the Principles shall govern. Information regarding the Privacy Shield program and evidence of our certification can be found by visiting https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Northpass commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Northpass at: privacy@northpass.com

Northpass has further committed to refer unresolved privacy complaints under the EU-US and Swiss- US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

We remain responsible and liable under the Principles if third-party agents that we engage to process your personal information on our behalf do so in a manner inconsistent with the Principles, unless we can prove that we are not responsible for the event giving rise to any harm you may incur.

Please be a Grown Up: User Age Requirements and Children’s Privacy

Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from children under the age of 13. We take those age-related requirements very seriously, and consistent with them, do not intend for this Site or the Service to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 13. If we become aware that anyone under the age of 13 has submitted personal information to our Site without verifiable parental consent, we will delete that information and will not use it for any purpose whatsoever. If you are the parent or guardian of a person under the age of 13 who has provided personally identifiable information to us without your approval, please inform us by contacting us at the email address below and we will remove such information from our database. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.

Things Happen: We do what we can to ensure Your Privacy

We will take all reasonable security precautions to protect your personal information provided to our Site. Due to the inherently open and somewhat risky nature of the Internet, however, we cannot guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction or alteration will not occur. We disclaim any liability for any theft or loss of, unauthorized access or damage to or interception of any data or communications. You should also note that third party companies we engage to provide us with services either to help us in our business, or to perform functions we would otherwise perform ourselves, will have incidental access to your information, including your personal information, as part of the work they perform. We require that they enter into confidentiality and other agreements, but cannot guarantee their compliance.

United States Data Security Laws: Submitting Information Outside the United States

Because Northpass is based in the United States, this privacy policy is consistent with United States law and practice and is not adapted to other laws including European data security laws. By agreeing to this privacy policy, you consent to Northpass transmitting to and processing data in the United States, a jurisdiction whose laws may not offer data protections equivalent to your home country’s and Northpass will apply the laws of the United States including as embodied in this privacy policy in place of data protections under your country’s law. That is, you freely and unambiguously consent that terms of this privacy policy, not your home country’s laws, control how Northpass will process personal data about you.

California Privacy Rights

California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties. To make such a request, please contact us at privacy@northpass.com with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

Changes to this Privacy Policy

We reserve the right to change or update this policy from time to time. Please check our site periodically for such changes since all information collected is subject to the policy in place at that time. Typically, we will indicate the effective/amendment date at the beginning of this policy. If we feel it is appropriate, or if the law requires, we’ll also provide a summary of changes we’ve made near the end of the new policy.

Contacting Us If you have questions or suggestions regarding this privacy policy, please contact us at privacy@northpass.com.